ANTI-MONEY LAUNDERING (AMLA) LAW (R.A. NO.
9160) (AS AMENDED BY R.A. 9194, R.A. 10167, R.A.
10365 [2013] & R.A. 10927 [2017]
WHAT IS MONEY LAUNDERING?
The word “Money Laundering” came from Al
Capone, an Italian Mafia which business is
prostitution, liquor sales, etc. that are paid
by cash. Their income from their illegal
transactions are put in a legitimate business,
that was a laundry shop.
 Activities intended to disguise the
origins of the proceeds of the crime
through processes that transform illegal
inputs into apparently legitimate
sources. (yung maduming pera, hugasan
mo pinamukha mong malinis)
PURPOSE (SEC. 2)
To protect and preserve the integrity and
confidentiality of bank accounts and to
ensure that the Philippines shall not be used
as a money laundering site for the proceeds
of any unlawful activity.
 Para hindi tayo maging safe haven for
money launderers
ANTI-MONEY LAUNDERING
COUNCIL (AMLC)
Composed of Governor of BSP as chairman,
Commissioner of IC, and Chairman of the SEC
as members
UNANIMOUS DECISION
The AMLC shall act unanimously in
discharging its functions as defined in the
AMLA and in these Rules.
IN CASE OF THE INCAPACITY, ABSENCE OR
DISABILITY OF ANY MEMBERS
 the officer duly designated or authorized
to perform the functions of the
Governor of the BSP, the Chairman of
the SEC, or the Insurance Commissioner,
as applicable, shall act in his place in the
AMLC.
FUNCTIONS OF THE AMLC
(1) to require and receive covered OR
SUSPICIOUS transaction reports from
covered institutions;
(2) to issue orders addressed to the
appropriate Supervising Authority or the
covered institution to determine the
true identity of the owner of any
monetary instrument or property
subject of a covered OR SUSPICIOUS
transaction report, or request for
assistance from a foreign State, or
believed by the Council, on the basis of
substantial evidence, to be, in whole or
in part, wherever located, representing,
involving, or related to, directly or
indirectly, in any manner or by any
means, the proceeds of an unlawful
activity;
(3) to institute civil forfeiture proceedings
and all other remedial proceedings
through the Office of the Solicitor
General;
(4) to cause the filing of complaints with the
Department of Justice or the
Ombudsman for the prosecution of
money laundering offenses;
(5) TO INVESTIGATE SUSPICIOUS
TRANSACTIONS AND COVERED
TRANSACTIONS DEEMED SUSPICIOUS
AFTER AN INVESTIGATION BY THE AMLC,
 money laundering activities and other
violations of this Act;
(6) TO APPLY BEFORE THE COURT OF
APPEALS, EX-PARTE, FOR THE FREEZING
OF any monetary instrument or
property alleged to be proceeds of any
unlawful activity AS DEFINED UNDER
SECTION 3 (i) HEREOF;
(7) to implement such measures as may be
inherent, necessary, implied, incidental
and justified under the AMLA to
counteract money laundering. Subject
to such limitations as provided for by
law, the AMLC is authorized under Rule
7 (7) of the AMLA to establish an
information sharing system that will
enable the AMLC to store, track and
analyze money laundering transactions
for the resolute prevention, detection
and investigation of money laundering
offenses. For this purpose, the AMLC
shall install a computerized system that
will be used in the creation and
maintenance of an information
database;
(8) to receive and take action in respect of
any request from foreign states for
assistance in their own anti-money
laundering operations as provided in the
AMLA.
The AMLC is authorized under Sections 7
(8) and 13 (b) and (d) of the AMLA to
receive and take action in respect of any
request of foreign states for assistance
in their own anti-money laundering
operations, in respect of conventions,
resolutions and other directives of the
United Nations (UN), the UN Security
Council, and other international
organizations of which the Philippines is
a member. However, the AMLC may
refuse to comply with any such request,
convention, resolution or directive
where the action sought therein
contravenes the provisions of the
Constitution, or the execution thereof is
likely to prejudice the national interest
of the Philippines.
(9) to develop educational programs on the
harmful impacts of money laundering,
its methods, how to avoid it, and how to
prosecute and punish violators.
(10) to enlist any government branch,
department, bureau, office, agency, or
instrumentality, including government-
owned and controlled corporations, in
any and all anti-money laundering
operations, including the use of its
personnel, facilities, and resources to
more effectively prevent, detect,
investigate, and prosecute money
laundering offenses.
The AMLC may require the intelligence
units of the Armed Forces of the
Philippines, the Philippine National
Police, the Department of Finance, the
Department of Justice, their attached
agencies, and other domestic or
transnational governmental or non-
governmental organizations or groups
to disclose all information that may help
prevent, investigate, and prosecute
money laundering offenses and other
violations.
(11) TO IMPOSE ADMINISTRATIVE
SANCTIONS FOR THE VIOLATION OF
LAWS, RULES, REGULATIONS AND
ORDERS AND RESOLUTIONS ISSUED
PURSUANT THERETO.
DEFINITION OF TERMS (SEC.
3)
MONEY INSTRUMENT (SEC. 3C)
Refers to:
(1) Coins or currency of legal tender of the
Philippines, or of any other country;
(2) Drafts, checks and notes;
(3) Securities or negotiable instruments, 21. Caves protection law
bonds, commercial papers, deposit 22. Carnapping
certificates, trust certificates, custodial 23. Child abuse
receipts or deposit substitute 24. Child porno
instruments, trading orders, transaction 25. Malversation
tickets and confirmations of sale or 26. Mining laws
investments and money market 27. Migrant workers and OFWs
instruments; 28. Terrorism
(4) Contracts or policies of insurance, life or 29. Terrorism financing
non-life, and contracts of suretyship; 30. Wildlife protection
and 31. Bribery and corruption of public officers
(5) Other similar instruments where title 32. Human trafficking
thereto passes to another by 33. Intellectual property law violations
endorsement, assignment or delivery. 34. Voyeurism (Photo and Video) (when you
UNLAWFUL ACTIVITY (SEC. 3C-41) secretly record a person with his/her
private part exposed w/o his/her
1. Kidnapping for ransom knowledge/consent)
2. Drug offenses *violation of specific COVERED
provisions of the Comprehensive
Dangerous Drugs Act of 2002) PERSONS/INSTITUTIONS (SEC.
3. Graft and corrupt practices Report to the AMLC all covered and
4. Plunder suspicious transactions within 5 working
5. Robbery and extortion days from occurrence thereof.
6. Jueteng and masiao
7. Piracy on the high seas
8. Qualified theft (kapag nasa position with
trust and confidence yung nagnakaw)
9. Swindling
10. Smuggling
11. E-commerce violations
12. Hijacking, destructive arson and murder,
including those perpetrated by terrorists COVERED PERSONS/INSTITUTIONS
against non-combatants and similar Natural or juridical, refer to:
(civilian) targets
13. Securities fraud (1) Bank, non-banks, quasi-banks, trust
14. Similar offenses punishable under the entities, foreign exchange dealers,
penal laws of foreign countries pawnshops, money changers,
15. Frauds and illegal transactions under remittance and transfer companies and
Articles 213-216 RPC other similar entities and all other
16. Forgeries and Conterfeiting persons and their subsidiaries and
17. Forestry violations affiliates supervised or regulated by the
18. Fisheries violations BSP;
19. Firearms violations (2) Insurance companies, insurance agents,
20. Fencing (bumili ka ng mga nakaw na insurance brokers, professional
bagay whether you know it or not) reinsurers, reinsurance brokers, holding
 companies, holding company systems (iii) providing a registered office,
and all other persons and entities business address or
supervised and/or regulated by the accommodation,
Insurance Commission (IC). correspondence or
(i) Securities, dealers, brokers, administrative address for a
salesmen, investment houses company, a partnership or any
and other similar persons other legal person or
managing securities or arrangement
rendering services as (iv) acting as (or arranging for
investment agent, advisor, or another person to act as) a
consultant, nominee shareholder for
(ii) Mutual funds, close-end another person
investment companies, (6) persons who provide any of the
common trust funds, and other following services:
similar persons, and (i) managing of client money,
(iii) Other entities administering or securities or other assets
otherwise dealing in currency, (ii) management of bank, savings or
commodities or financial securities accounts
derivatives based thereon, (iii) organization of contributions for
valuable objects, cash the creation, operation or
substitutes and other similar management of companies
monetary instruments or (iv) creation, operation or
property supervised or management of juridical
regulated by the SEC. persons or arrangements, and
(3) jewelry dealers in precious metals, buying and selling business
who, as a business, trade in precious entities
metals, for transactions of more than (7) casinos, including internet and ship-
P1,000,000 based casinos, with respect to their
(4) jewelry dealers in precious stones, who, casino cash transactions related to their
as a business, trade in precious stones, gaming operations. (as amended 2017
for transactions of more than because of the BANGLADESH BANK
P1,000,000 HEIST 2016)
(5) company service providers which, as a
business, provide any of the following
services to third parties:
(i) acting as a formation agent of
juridical persons
(ii) acting as (or arranging for
another person to act as) a
director or corporate secretary
of a company, a partner of a
partnership, or a similar position
in relation to other juridical
persons
COVERED TRANSACTIONS (SEC.
3B)
 Transaction, in cash or other monetary
instrument, involving a total amount in
excess of P500,000 (threshold amount)
within one banking day.
 For casinos: a single casino transaction
involving an amount in excess of
P5,000,000 or its equivalent in any
other currency.
SUSPICIOUS TRANSACTIONS
Suspicious transactions are transactions
with covered institutions, regardless of the
amounts involved, where any of the
following circumstances exist: (SUSU-DIC)
1. No underlying legal or trade obligation,
purpose or economic justification.
2. Client is not properly Identified.
3. Amount involved is not Commensurate
with client’s business or financial
capacity.
4. Transaction is Structured in order to
avoid being the subject of reporting
requirements under the Act.
5. Transaction which Deviates from client’s
profile and/or client’s past transactions
with covered institutions.
6. Transaction related to an Unlawful
activity or offense, including those
committed or about to be committed.
7. Similar or analogous transactions.
MONEY LAUNDERING
OFFENSE (SEC. 4)
MONEY LAUNDERING
 Committed by any person who, knowing
that any monetary instrument or
property represents, involves, or relates
to the proceeds of any unlawful activity:
(PUTA-CA)
(a) Transacts said monetary instrument or
property;
(b) Converts, transfers, disposes of,
acquires, possesses or Uses (UP-MD-
CAT) said monetary instrument or
property;
(c) Conceals or disguises the true nature,
source, location, disposition, movement
or ownership of or rights with respect to
said monetary instrument or property;
(d) Attempts or conspires to commit money
laundering offenses referred to in
paragraphs (a), (b) or (c);
(e) Aids, abets, assists in or counsels the
commission of the money laundering
offenses referred to in paragraphs (a),
(b) or (c) above;
(f) Performs or fails to perform any act as a
result of which he facilitates the offense
of money laundering referred to in
paragraphs (a), (b) or (c) above.
Money laundering is also committed by any
covered person who, knowing that a
covered or suspicious transaction is required
under this Act to be reported to the Anti-
Money Laundering Council (AMLC), fails to
do so.
PREVENTIVE MEASURES AND
OBLIGATIONS OF COVERED
PERSONS (SEC. 9)
CUSTOMER IDENTIFICATION
 Covered institutions shall establish and
record the true identity of its clients
based on official documents. They shall
maintain a system of verifying the true
identity of their clients and,
o in case of corporate clients,
require a system of verifying
their legal existence and
organizational structure, as well
 as the authority and
identification of all persons
purporting to act on their
behalf.
 For trustee, nominee and agency
accounts: Verify and record the true and
full identity of the person(s) on whose
behalf a transaction is being conducted.
MINIMUM INFORMATION/DOCUMENTS
REQUIRED FOR CORPORATE ANS JURIDICAL
ENTITIES
(1) Articles of Incorporation/Partnership;
(2) By-laws;
(3) Official address or principal address;
(4) List of directors/partners;
(5) List of principal stockholders owning at
least 2% of capital stock;
(6) Contact numbers;
(7) Beneficial owners, if any; and
(8) Verification of the authority and
identification of the purporting to act on
behalf of the client.
RECORD KEEPING
All records of all transactions of covered
institutions shall be maintained and safely
stored for five (5) years from the dates of
transactions. Said records and files shall
contain the full and true identity of the
owners or holders of the accounts involved
in the covered transactions and all other
customer identification documents.
 If closed account-at least 5 years from
the dates when they were closed.
 If a money laundering case was filed-file
must be retained until it is confirmed
that the case has been finally resolved
or terminated by the court.
PROHIBITION AGAINST CERTAIN
ACCOUNTS
 Covered institutions shall maintain
accounts only in the true and full name
of the account owner or holder. The
provisions of existing laws to the
contrary notwithstanding, anonymous
accounts, accounts under fictitious
names, and all other similar accounts
shall be absolutely prohibited.
 No new accounts shall be opened and
created without face-to-face contact
and full compliance with the minimum
documentary requirements for
individual customers.
 Peso and foreign currency non-checking
numbered accounts shall be allowed:
(AS LONG AS HINDI SYA CHECKING
ACCOUNT)
o Provided, That the true identity of
the customers of all peso and
foreign currency non-checking
numbered accounts are
satisfactorily established based on
official and other reliable
documents and records, and that
the information and documents
required under the provisions of
these rules are obtained and
recorded by the covered
institutions.
FREEZE ORDER (SEC. 10)
When?
- Upon a verified ex parte petition by the
AMLC and after determination that
probable cause exists that any monetary
instrument or property is in any way
related to an unlawful activity as defined
in Sec.3(i) hereof, the Court of Appeals
may issue a freeze order which shall be
effective immediately, for a period of 20
days.

- Under the Anti-Terror Law (if related ang
account mo sa financing of terrorism)
INQUIRE INTO DEPOSITS OR
INVESTMENTS (SEC. 11)
BANK INQUIRY WITH BANK
ORDER
When?
- Upon order of any competent court (CA)
based on an ex parte (hindi na pag-
aawyan, hindi na pasasagutin yung
kabila) application in cases of violation
of this Act, when it case been
established that there is probable cause
that the deposits or investments,
including related accounts involved, are
related to an unlawful activity or a
money laundering offense.
- Under the Anti-Terror Law:
a. Any property or funds that are in any
way related to financing of terrorism
as defined and penalized under RA
10168.
b. Violation of Sections 4,6,7,10,11 or
12 of the Anti-Terrorism Law.
c. Property or funds of any person or
persons in relation to whom there is
probable cause to believe that such
person or persons are committing or
attempting or conspiring to commit
or participating in or facilitating the
financing of terrorism.
BANK INQUIRY WITHOUT COURT
ORDER
NO COURT ORDER SHALL BE REQUIRED IN:
1. Kidnapping for ransom.
2. Drug offenses (violation of specific
provisions of the Comprehensive
Dangerous Act of 2002).
3. Hijacking, destructive arson and
murder, including t5hose
perpetrated by terrorists against
non-combatants and similar
(civilian) targets.
4. Similar foreign offenses.
5. AMLC’s authority under the Anti-
Terror Law.
ASSET FORFEITURE (SEC. 12)
AMLC may institute civil forfeiture (kunin
yung asset nay un for the benefit of the
govt.) proceedings and all other remedial
proceedings through the Office of the
Solicitor General.
When?
 When there is a covered transaction or
suspicious transaction report made and
 the court has, in a petition filed for the
purpose, ordered the seizure of any
monetary instrument or property, in
whole or in part, directly or indirectly
related to said report.
If the monetary instrument or property to be
forfeited cannot be located, the convicted
may be ordered to pay the value of the
monetary instrument or property in lieu of
forfeiture.
BENEFICIAL OWNERSHIP
“Beneficial Owner” refers to any natural
person who:
1. Ultimately owns or controls the
customer and/or on whose behalf a
transaction or activity is being
conducted; or
2. Has ultimate effective control over a
legal person or arrangement.
SAFE HARBOR PROVISION
No administrative, criminal or civil
proceedings, shall lie against any person for
having made a covered or suspicious
transaction report in the regular
performance of his duties in good faith,
whether or not such reporting results in any
criminal prosecution under this Act or any
other law. (Walang administrative, criminal
or civil proceedings ang pwedeng ikaso sa
mga covered persons an nag-file lang naman
ng covered or suspicious reports)
UPDATES ON AMLA
RA 11521 which was signed into law on Jan.
29, 2021, introduces amendments to AMLA
in a bid to prevent the country from being
included on the “gray list” or countries with
weak policies against dirty money by the
Financial Action Task Force.
SALIENT AMENDMENTS TO AMLA
1. included transactions in excess of
P500,000 of Philippine Offshore
Gaming Operators (POGOs) within the
purview of AMLA.
2. Included real estate brokers and
developers as “covered persons,” but
only for single cash transactions
involving amounts in excess of P7.5
million, effectively narrowing the
burden or reportorial requirements for
high-risk transactions.
3. Included tax crimes with a threshold in
excess of P25 million and violation of
the Trade Management Act on the
financing of the proliferation of
weapons of mass destruction as a
predicate offense to money laundering
and set a threshold to excess of P25
million.
4. GRANTED THE AMLC THE FOLLOWING
ADDITIONAL POWERS:
o Authority to require, receive, and
analyze covered or suspicious
transaction reports from covered
persons.
o Issue subpoenas and conduct search
and seizures of suspicious accounts
o Preserve, manage, or dispose assets
pursuant to freeze order,
preservation order, or judgement of
forfeiture.
o To implement targeted financial
sanctions in relation to the
proliferation of weapons of mass
destruction and their financing.
5. Adopted information security and
confidentiality proposals, safeguarding
information processed through AMLC
and deterring the council’s staff from
leaking or misusing information.